June 5, 2015 , 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey

Ave, SE Washington, DC 20590
Re: Section 333 of the FAA Reform Act of 2012 Dear Administrator, I, Robert D. Mcghee , herein referred to as (the petitioner), am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that the petitioner , Robert D. Mcghee, an owner and operator of a small unmanned air craft system (sUAS), petition for exemption from the Federal Aviation Regulations listed below and any regulation as required by the FAA that is deemed necessary in order to conduct commercial UAS operations as described. The requested exemption would pe rmit the petitioner to pursue, safe, professional, for profit services to private and public entities within the State of Florida and adjoining states utilizing a small unmanned aircraft system (sUAS) for aerial still and video data capture for, but not li mited to the following purpose: *Real Estate Sales *Residential/Commercial Roof inspections/ *Crop Inspection *Property Video Survey *Photo/Videography of rural contracted outdoor recreational activities on private and public use lands (Prior Permission and coordination Only) *Fire Survey and Rural Search Assist to local public and private entities. As described herein, the petitioner is a certified and current, FAA licensed Private Pilot. The petitioner has over 30 years of aviation experience within the Private Aviation community. The petitioner has been flying Aircraft within the State of Tennessee and Florida for over 30 years and is experienced and familiar with the standard operating practices and procedures, as well as safety attitudes and safety requirements within the aviation industry. The petitioner is familiar with the C.F.R. and FAR, all classes of Airspace, Aircraft agreements and standard operating practices and procedures within the State of Florida. Furthermore the petitioner has over 4 0 years of experience flying Radio Controlled Aircraft including airplanes, helicopters and drones and warrants to conduct operations over private or public lands in the above uses with safety for the general public as the greatest priority. In addition, the safe integration of the UAS into the national airspace without interference or hazard to manned aircraft is of utmost importance. The proposed services are offered with the intent of enhancing the development and safe operation of unmanned aircraft s ystems, realizing that current manned aircraft operations pose a much greater risk of personal injury and or death and extensive property damage. The use of UAS could fulfill a service to consumers and small entities that would otherwise not exist due to the risks and costs involved with manned aircraft. The initial (sUAS) to be utilized during the operations is a consumer class helicopter, quad

- rotor aircraft. It is manufactured by Yuneec, Inc. and has the manufactures model designation Q500 Typhoon. It is an advanced (sUAS) with state of the art safety features, GPS lock, altitude, position hold stabilization, smart mode, angle mode follow me and return to home mode. The ground station has telemetry with altitude, groundspeed, GPS location and batter y life for both the transmitter and aircraft as well as an audible and vibration alert for aircraft low battery. Aircraft LED visual alert indicators for low battery, GPS loss, and communication loss. The UAS has a first person view on the controller that is not to beused for flight by the PIC. The UAS has the ability to link with a smartphone or tablet for video link

separate from the on

2 board display if needed. The UAS has separate radio frequencies for telemetry and video downlink and aircraft c ontrol. See the following manufactures specifications. Yuneec Q500 Typhoon, quad copter Flight Time Up to 25 Minutes Height 240mm (9.45 in) Width 420mm (16.54 in) Diagonal Length W \ O Rotor Blades 565mm (22.2 in) Prop eller/Main Rotor Diameter 330mm (13.0 in) Weight W/O and Payload 1130g (40.0 oz) Battery 5400mAh 3S 11.1V LiPo 3 Flight Modes Smart, Angle and Home Modes Maximum Flying Height Default 400 Feet AGL (Adjustable via the Q500 GUI) Maximum Rotational Velocity 65 ° /s Maximum Bank Angle 35 ° Maximum Climb Rate in Smart and Angle mode 3m/s Maximum Descent Rate in Smart and Angle mode 2m/s Takeoff Weight With Battery and CGO2

- GB 1700g (60.0 oz) Radio Cont rol Frequency Band 2.4GHz Maximum Groundspeed 15 MPH
ST10 Personal Ground Station
Operating System A ndroid TM Number of Channels 10 Control Transmission Distance/Range FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 40 0m (1312.34 ft) Robust Radio Control Modulation Yuneec Protocol Video link Frequency Band 5.8GHz Video Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 f t) Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times. Flight Systems Telemetry Data On Screen Display (OSD) Yes LED Backlit LCD Screen Capacitive Multi

- Touch 4.5 ” Tactile (Vibrating) and Audible Feedback Yes Built

- In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh CGO2

- GB Camera Gimbal System Focusing System Aerial Optimized Fixed Focus Video Field of View 130 ° Transmission Band 5.8GHz Video Transmission Distance/Range FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) with ST10 UAS are often seen as superior to manned helicopters due to the smaller size and lower costs, reduced noise and as such, a much smaller envir onmental and safety impact. The petitioner requests exemption to operate a Yuneec, Q500 Typhoon equipped with a three

- axis CGO2 Gimbal and Camera, both products of Yuneec. This sUAS has a pre

- programmed limit for the altitude above ground level at 400 fe et the controller. These limits are preset at the factory and will be kept at those limits, which currently comply with the AMA’s and FAA requirement for Visual Line of Sight limitation and an AGL limitation. The ground station is also programmed with a safety feature that disables motor start up if within Class B, and C airspace boundaries. The Q500 also has the failsafe

- automated feature of return to home in the event that communication is lost between the ground station and the aircraft.
In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The petitioner will

-- a. Only operate its UAS in direct visual line of sight of the pilot and observer without use of a visualaid other than corrective lenses. b. Oper ate at an altitude no greater than 400 feet above the ground.

c. Operate with due vigilance and known practiced see and avoid scanning techniques to avoid any conflicts with manned or other UAS aircraft that may enter the UAS operating area. The UAS flig ht will be immediately terminated if a potential conflict may exist. d. Operate over private or public sites only with prior permission from property owner or owner’s agent or legal authorities as allowed by law. e. Terminate flight when any unsafe con dition exists. f. Terminate flight when battery voltage drops to 30% of battery capacity or when the 1st low battery alert occurs per the Q500 Typhoon Instruction Manual, not to exceed 18 minutes run time. g. Operate at a ground speed of 0 to 15 mph durin g on site missions. h. Operate in accordance with the guidance and standards set forth by the AMA, the UAS manufacturer and the administrator. i. Operate with a minimum crew for each operation consisting of the PIC and a visual observer in direct communic ation utilizing appropriate verbal, radio or cell phone as needed. j. Insure the sUAS operator on the controls will be at least a current Private Pilot with a class III medical. k. Provide ground instruction with standards and content currently accepted by the administrator for private pilot knowledge testing, to the observer and or UAS. The petitioner requests exemption from 14 CFR part 61.113 Private Pilot Privileges, Pilot in Command Section (a). Although the petitioner is a current certified Privat e pilot the petitioner may elect to utilize certified private pilots with class III medicals to conduct operations with the sUAS. In the Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certifi cate operating the Astraeus UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. The petitioner requests the same consideration and limitations as previously granted. Title 14 CFR part 91.7(a) Ci vil Aircraft Airworthiness. As no Airworthiness Certificate is available for this sUAS the petitioner requests exemption under this part utilizing a preflight inspection and the manufacturers documents for determining compliance of the sUAS airworthiness. The petitioner warrants compliance to part 91.7(b) in that the operation will only be conducted after a thorough preflight and premission planning inspection is completed, to include current and forecast weather, airspace, notams, area of operations, an d notice issued to non

- participating persons in local proximity. The petitioner will utilize the Yuneec, Q500 Instruction manual, quick start guide and the petitioners own pre
- flight checklist included in the attached supplements to determine the sUAS airw orthiness. The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitudes. The petitioner requests exemption from Section (c) with the following conditions and limitations. The petitioner requests the exemption due to the scope of the operations to be performed and the requirement to operate below 400 feet AGL. The Petitioners primary mission would be to record data or survey of persons, property or structures as listed above. The sUAS size, weight, speed and limited operating ti mes and area, as well as the soft materials used in the construction of the sUAS, would provide an equivalent or greater level of safety as intended under this part. The Q500 is a helicopter as defined by CFR Title 14, FAR Part 1, general definitions. The sUAS has a

4 vertical to near vertical descent in the event of a power failure. Fly

- a
- ways would be the greatest or most dangerous risk to non

- participating persons. The Q500 has no documented (fly

- away), while operated under GPS lock within the p arameters of the Q500 operating instructions. The Q500 is a verystable, low rotor speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar sized

UAS. In an emergency the sUAS would be quickly brought down per the loss of control pr ocedure as described in the emergency procedures checklist, adequate time to complete the procedure would exist due to the 0 to 15 mph operational groundspeed of the Q500. The risk to persons 100 feet away would be at no greater risk than persons located 5 00 feet away. The petitioner requests exemption from the 500

- foot altitude restriction and the 500

- foot stand off restriction from persons, property or vessel applied to previous grants of exemptions. The exemption is requested with the following conditi ons and limitations in conducting the petitioners operations

— a. The sUAS will be operated at an altitude of no more than 400 feet above ground level. b. The sUAS will not be operated at greater than a 400

- foot slant distance from the PIC. c. The sUAS wi ll not be operated over any non

- participating person. d. The sUAS will not be operated over a non

- participating property, structure or vessel without prior permission from the property owner or legal representative. e. The sUAS will maintain a minimum s lant distance of 100 feet from any non

- participating person and will increase the distance proportionally by 50 ft. per 50 ft. of altitude. At no time will the sUAS be operated closer than a 100

- foot slant distance to a non

- participating person unless tha t person is behind a protective barrier or shielded from possible debris in the event of a crash. f. A minimum of 2 hour notice will be distributed to all residences or businesses of a scheduled operation in an urban business or residential area within 50 0 feet of the operation, informing of the time, location and safety hazards to persons or property, the notice will include a phone number to voice objections or concerns. g. Warning signs will be displayed on the perimeter of the safety zone to alert pass ers
- by of the hazard and warning to stay back and behind cover. If the safety zone is breeched, flight will be immediately terminated. h. The sUAS will be operated over public rural lands with the same stand off distance and altitude restrictions afforded persons, property and vessels per e. above. The petitioner requests exemption from 14 CFR Part 91.121, Altimeter settings. The UAS will not have a typical barometric altimeter onboard the aircraft, the petitioner intends to operate the UA within VLOS and at or below 400 feet AGL, combined with the petitioner’s intention to limit the altitude of the UAS through flight limit function on the UAS, has been previously ruled to be a sufficient method for ensuring the UAS operations do not adversely affect s afety. The altitude information will be generated by GPS equipment installed onboard the aircraft, and/or a static pressure sensor (barometer), which aids in estimating the altitude. The petitioner requests exemption from 14 CFR Part 91.151, Fuel requir ements for flight in VFR conditions, prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted an Exemption N os. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions. The petitioner’s UAS provides low battery warnings that indicate the PIC must command the UA’s return to the launch point when low battery capacity voltage is reached. The UAS al so provides 2 and 3rd increased intensity critical low battery warnings through audio and vibration indicating that the UA must be landed immediately, additionally a fail safe automatic landing will occur when the battery is at absolute critical low voltag e. The petitioner warrants that the sUAS will be landed immediately upon the 1st low battery alert or no longer than 18 minutes which ever occurs first. The petitioner will not initiate a flight unless (considering wind and forecast weather conditions) th ere is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining.The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401

- 417),) Maintenance required,

91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration,

5 91.409(a)(1) and (2) Inspections, and 91.417(a) and (b) Maintenance records. Currently the manufacturers maintenance procedures govern preflight w ith no limits other than on

- condition. The petitioner will complete all authorized component replacements at the petitioner’s base of operations or in the field as required. The manufacturer or authorized repair center will complete any maintenance

or re pairs that cannot be completed by the petitioner. The petitioner warrants that preflight, post flight and maintenance procedures set forth in the petitioner’s supplements attached should provide an acceptable level of safety for the operations performed a nd is consistent with those of previous grants. In addition the petitioner will comply with any and all manufacturers updates for UAS and Ground station as well as any FAA directives and guidelines. An appropriate aircraft/maintenance logbook will be kep t with the sUAS ground station and base of operations as required, (See Supplement). As previously stated the petitioner has demonstrated over 30 years of safe aircraft service as a pilot. The petitioner requests the administrator to consider that the sa me professional standards and safe practices utilized by this petitioner would be an asset and greatly benefit the development and integration of the UA system into the National Airspace. Furthermore it is of this petitioner’s best interest as a current P rivate pilot to insure safe, compliant and professional operations for the furtherance of public safety in the aviation industry. Sincerely, Robert D. Mcghee, 13013 Air Way, Panama City, FL. 32404 Phone 850

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